Privacy Notice

Introduction

This document explains how Accessible Communications Ltd T/A Family Phone, collects, handles and uses your personal data when you use our phone App. It tells you how we use it responsibly, and how we keep it safe and secure.

There are a few things that we have to tell you to comply with data protection legislation (the UK GDPR and Data Protection Act 2018, and the EU GDPR).

Who are we?

We are Accessible Communications Ltd T/A Family Phone (‘Family Phone’) a privately owned company registered in England. We provide a software App that is downloaded to the operating system of your mobile phone and allows you as the person living with Dementia, and your family or carers to have an easy to use calling facility that can use video calling.

We have to tell you who the ‘Controller’ is, so that is Family Phone. We are not required to have a specific Data Protection Officer but we do have support and training for data protection. You can contact us at info@familyphone.io.

What data we need

We collect, store and use a small amount of personal data and information that you provide to us including:

If you a creating a Connection Account: 

• You name;
• Email address
• Your role/title within your family network or group.

If you are a Account Holder:

• your name;
• email address;
• Your role/title within your family network or group.

You may also upload images or photographs to help identify the registered users who are linked together on the App.

If you subscribe to our marketing or mailing lists, we will collect and use your name, email address and preferences.

We collect information from the payment system for the monthly subscription fee.

How we get the data and information, and why we have it.

Most of the data and information we process about you is provided by you for one of the following reasons:

• You purchase a subscription to the App service.
• You register for an account on the App.
• You subscribe to our mailing lists and/or marketing.
• You contact us to make an enquiry.

We will process details of mobile phone numbers to link devices to the account for the person living with Dementia.

We use this personal data and information solely to provide and maintain the service to you. 

Some information from marketing or mailing list contacts is used to help us improve the quality of the service which is important for continuing improvements of your experience using the App.

Why we need it – our legal or lawful bases

Data Protection legislation requires us to identify a legal basis to process your personal data. We have identified the following that Apply to personal data and your use of our App.

• Where you provide general personal data or information to purchase a subscription to the App service or register an account, this is with your CONSENT.
• For your uploaded photograph this is with your EXPLICIT CONSENT.
• By purchasing the App, you enter into a CONTRACT with us and we publish the Full Terms and Conditions on our App, with a shorter version on the App (suitable for mobile devices).
• Where you have subscribed to our mailing list or marketing, or you enter a competition, the legal basis will be CONSENT. You are able to withdraw or remove your consent at any time by contacting us at info@familyphone.io.
• We have a LEGAL OBLIGATION to collect certain information such as payment details as we have to comply with financial regulations and legislation e.g. HMRC for tax purposes.

Finally, to enable us to operate and administer our business, and to ensure that we can business plan effectively, we have a LEGITIMATE INTEREST in processing some limited personal information. This helps us to remain accountable to you.

How we store your data

Keeping your personal data safe and secure, and building your trust when using the service is important to us and we have policies and procedures to do this. We implement all appropriate and reasonable technical and organisational measures to protect your personal data and prevent unauthorised access or disclosure.

For example, we use a world-renowned cloud-based storage service that has very high levels of security and confidentiality. We aim to use the UK service but this may be based in EU so we have undertaken all necessary checks and ensure that we have a contract in place.

Any devices that we use are protected and all software including antivirus/firewall is kept up to date. For added assurance, we have contracts in place for any external service providers.

We do not

We do not allow any other third parties to have access to your personal data unless we are required to share your data with them by law or we are ordered to do so by a Court.

We do not sell, rent or trade your personal data.

We do not use your personal data for automated decision-making as defined in the data protection legislation. Nor do we use your data for profiling purposes.

How long we keep it

We have a retention schedule which details how long we keep data for. 

We will keep your personal data described above for up to 12 months after the end of your subscription with us. We will also keep certain date for a period that is required by law, for example financial records or HMRC records will be kept for 6 years. We may keep personal data for longer if have consented to us keeping it or you have asked us to keep it. 

When we no longer need to keep your personal data, or you chose to delete your account, we will then dispose of this by secure and permanent deletion (electronic records).

What are your rights?

You have a number of rights relating to the processing of your personal data. Importantly, this Privacy Notice meets the first right – the right to be informed.

You can ask to see the personal data that we hold about you (known as a Subject Access Request), or even as us to correct it or have it deleted (known as the right to erasure or to be forgotten). There are other rights such as restricting processing, data portability, objecting to processing, or rights linked to automated decision making.

You are not required to pay any fee for exercising your rights or making a request. If you do wish to do this, we usually have one month to respond to you. Please contact us at info@familyphone.io.

Where you have provided personal data with consent, you can withdraw this consent at any time. You can do this by clicking the ‘opt out’ link in any emails we send to you, or by sending an email to info@familyphone.io with the subject “withdraw consent” if you wish to do this. We must tell you that when you opt-out for us to use your data for your account, we will not be able to continue to provide this service to you.

More information on your rights can be found on the Information Commissioner’s App at www.ico.org.uk . 

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter as we would like the opportunity to resolve this with you.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Telephone 0303 123 1113 (local rate) or via their App at www.ico.org.uk.

Date published: April 2022 Version: 1.0

COOKIE NOTICE

Introduction

We are obliged to tell you about Cookies and what information these may gather and how it is used.

What is a Cookie?

A cookie is a small text file that is downloaded or dropped onto your computer or device automatically. This is stored on the hard drive. Each App you use will drop cookies if your browser allows it. There are generally three types of Cookies, 

• Session / Functional/ Essential / Strictly Necessary (the ones that are needed for the App to function properly)
• Permanent / Persistent (the ones that remain for 6 months max and remember details like logins and passwords)
• Third-party / Analytical / Non-Essential (those used by other Apps and advertisers or for analytics or browsing habits)

Our use of Cookies

Our App uses Functional and Third-Party cookies.

The Functional cookies are those that necessary for our App to work. 

For the Third-party cookies, you should read the section below on how to decline these. If declined the Third-Party cookies will not be placed on your device.

The Third-Party cookies do provide us with analytical data about use of our app, which resources or pages were viewed and more. We need your consent for these. We use Google Analytics and Google Ad Tracking which will place cookies on your device. We recommend you review Google’s information on cookies and privacy notices on their App.

We do use a third-party service named Twilio to help with connecting your calls. Twilio do download cookies when the app is used and you should review their published information about the cookies that they use and you options for these. The link to the section on their website is: https://www.twilio.com/legal/privacy#cookies-and-tracking-technologies 

We do use scripts or native social media buttons to link you to our social media and these may build profiles of your use. These are known as Third-party cookies. These include Facebook (Meta) and Twitter. We recommend you read the privacy and cookie notices on each social media platform for more information about these.

The data that the Cookies collect.

During your use of the Family Phone App, the services and information you see, along with a cookie, are downloaded to your device.

Depending on the type of cookie, limited personal data about you or your device or your use of our App will be collected. This may include:

• Data that identifies you or your device.

Your IP address (an IP address is a number that can uniquely identify a specific computer or other network devices on the internet), login information, browser type and version, time zone setting, browser plug-in types, geolocation information about where you might be, operating system and version.

• Data on how you use our App.

The services used or viewed, our app response times, download errors, and other actions.

We use Analytics software to look at IP addresses and cookies for the purpose of enhancing your user experience. This information is not used to develop a personal profile of you and the log files are regularly purged.

How do I stop cookies?

All computers and devices (including the internet browser you use) have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline cookies – you can search for information on how to do this by checking the ‘Help’ menu of your browser.

Unfortunately, choosing to decline cookies can impact on the use of our App and you may not be able to take full advantage of our App features.

Other Third-party cookies.

Any links to other services from our App may also incorporate cookies over which we have no control. These cookies may be dropped (downloaded) when you click on the service link.

Future Cookies.

As many companies and organisations do, we are constantly developing our App and services, to provide the best experience and most up-to-date services that we can for you.  Developments can include the use of tracking cookies that will help us analyse how people have found our App amongst other tracking services. We recommend that you review this cookie policy from time to time as we will update the list of cookies if any new ones are implemented.

More information.

Further advice is available from the Information Commissioner’s Office on their App at: https://ico.org.uk/your-data-matters/online/cookies/, including how to control cookies on your browser.

Date Reviewed May 2022 Version No: 1.0